Safeguarding Policy

Season 2019/20
Introduction
The Premier League places great importance on
safeguarding and we believe that everyone has
the right to enjoy football in a safe and inclusive
environment.

We are committed to creating a culture where

safeguarding responsibilities and procedures
for raising concerns are widely understood and
embedded in our values. This Policy sets out our
expectations of everyone involved with the Premier
League and underpins the work undertaken to
promote and protect the safety and welfare of
Children, Young People and Adults at Risk.

Please familiarise yourself with this Policy and let us

know if you have any questions.

Richard Masters
Interim Chief Executive

e: safeguarding@premierleague.com
Our commitment
Aims and how we will
achieve these
Recognising and responding
to abuse, poor practice and
other safeguarding concerns
Managing safeguarding
concerns
Safer working practices
Appendices
4
 ision 5
V
Core principles 5
Evaluation and review 5
Definitions 5
Designated safeguarding Staff 6
External safeguarding contacts 6
7
Getting the right people involved 8
Raising awareness 8
Propriety and behaviour 8
Relationships of trust 9
10
Signs and indicators 13
 Responding to disclosures, safeguarding 13
incidents and concerns
Recording information 14
Confidentiality 15
Communication and media protocols 15
Support for Staff 15
16
Football’s safeguarding framework 17
Employer role 17
Football Authorities 17
Statutory agencies 18
The Disclosure and Barring Service 18
Charity Commission 18
Data protection 19
Listening culture 19
20
 aintaining professional boundaries
M 21
Communication 21
Creating a safe environment 21
Supervision and ratios 22
Lone working and one-to-one situations 22
Gifts, rewards and selection 22
Behaviour management 23
Photography and video footage 23
Transport 23
First aid and administration of medication 23
24
 Appendix 1: P
 ossible signs and indicators of 24
abuse, bullying and other
safeguarding concerns
Appendix 2: S afeguarding Referral Form 30
Appendix 3: F
 lowcharts – Responding to 36
safeguarding concerns
Appendix 4: F
 lowcharts – Stakeholder roles 38
and procedures
Our commitment
Safeguarding is important to us and we are committed to raising
awareness and empowering everyone we engage with to create safe
environments, identify and report concerns.

This Policy outlines our approach to safeguarding and applies to

everyone involved with the Premier League and Premier League
Charitable Fund, as we all share a responsibility for promoting and
protecting the safety and welfare of Children, Young People and Adults
at Risk, irrespective of individual roles and responsibilities.

Should any policies or regulations conflict, the safety and welfare of

Children, Young People and Adults at Risk should always
take precedence.



4
Vision
To offer an enjoyable experience and to create
inclusive and welcoming environments where Children,
Young People and Adults at Risk are safe, valued and
respected.
 of the Premier League.
Core principles
• Safeguarding is everyone’s responsibility and we
recognise our duty to promote and protect the
safety and welfare of Children, Young People and
Adults at Risk.
• Everyone has the right to protection from abuse,
mistreatment and exploitation in any form.
• We strive to create an environment where everyone
is empowered to protect themselves and others.
• Working together underpins the work undertaken to
safeguard Children, Young People and Adults at Risk.
• Robust and transparent governance arrangements
for safeguarding are essential.
 protect them from harm.
Evaluation and review
We will regularly assess the implementation and
effectiveness of this Policy which will be reviewed
annually or whenever there are changes in legislation,
key functions or persons within the organisation,
following new or revised government or statutory
guidance, or after dealing with any safeguarding
concern. The most current version of this Policy will
always be available to view or download from the
Premier League Intranet and website.
Definitions
Activity means any activity or series of activities,
arranged by or in the name of the Premier League or
Premier League Charitable Fund, for Children, Young
People and/or Adults at Risk, or to be attended by
Children, Young People and/or Adults at Risk.
Adult at Risk means any person aged eighteen or
over who has needs for care and support (whether or
not the local authority is meeting any of those needs)
and is experiencing, or at risk of, abuse or neglect and
as a result of those care and support needs is unable
to protect themselves from either the risk of, or the
experience of abuse or neglect. This may include people
with learning disabilities, sensory impairments, mental
health needs, older people and people with a physical
disability or impairment. It may also include people who
are affected by the circumstances that they are living
in, for example, experiencing domestic violence. An
individual’s level of vulnerability to harm may vary over
time depending on the circumstances they are in and
their needs at that time.
Child, Children, Young Person and Young People
means any person(s) who have not yet reached their
eighteenth birthday.


Club means an association football club in membership
Club Community Organisation (“CCO”) means an
organisation established or affiliated to a professional
football club that exists to achieve a positive impact in
the communities in which they operate and in the lives
of those that access their services.
Premier League Charitable Fund (“PLCF”) is the
charity which has the principal objective of distribution
and governance of funding in the form of grants
to organisations, particularly Club Community
Organisations, enabling them to deliver agreed
community focused initiatives which have a positive
influence on a wide range of beneficiaries.
Safeguarding: Children and Young People
Safeguarding Children and Young People is the action
that is taken to promote the welfare of children and
This means:
• Protecting Children and Young People from abuse
and maltreatment;
• Preventing harm to their health or development;
• Ensuring they grow up with the provision of safe and
effective care; and
• Taking action to enable all Children and Young
People to have the best outcomes.
Safeguarding: Adults at Risk
Safeguarding Adults at Risk means protecting an
adult’s right to live in safety, free from abuse and
neglect. It is about people and organisations working
together to prevent and stop both the risks and
experience of abuse or neglect, while at the same time
making sure that the adult’s wellbeing is promoted.
Abuse of adults links to the circumstances rather than
the characteristics of the people experiencing the harm.
An individual’s level of vulnerability to harm may vary
over time depending on the circumstances they are in
and their needs at that time.
Labelling groups of people (such as people with learning
disabilities or older people) as inherently ‘vulnerable’
is seen to be disempowering. Instead the Care Act
describes adults potentially ‘at risk’ from harm or abuse.
Staff and Partners means any persons employed or
deployed by a Club or CCO whether in a paid, voluntary,
consultancy or third-party capacity.
The Football Association (“The FA”) is English
football’s governing body.

5
Safeguarding Policy Season 2019/20 - Our commitment

Designated safeguarding Staff External safeguarding contacts

While safeguarding is everyone’s responsibility, our
Safeguarding Team hold specific strategic and
operational responsibilities for safeguarding within
the Premier League.
The FA Safeguarding Team
Premier League Safeguarding Team:
 t: 0800 169 1863 and ask to speak to The FA
Safeguarding Team 

Jess Addicott
e: safeguarding@thefa.com
Head of Safeguarding
t: 020 7864 9173
e: jaddicott@premierleague.com

Christie Ferguson
Contact the NSPCC helpline by calling 0808 800 5000
Safeguarding Manager
or by emailing help@nspcc.org.uk to get advice
t: 020 7864 9224
or share your concerns about a child. Trained
e: cferguson@premierleague.com
professionals are available 24 hours a day, 7 days a
Kevin Plumb week.
Director of Legal Services and Senior
Safeguarding Lead
t: 020 7864 9175
e: kplumb@premierleague.com
Contact the Ann Craft Trust safeguarding adults
Evan Ray advice helpline by calling 0115 951 5400.
Head of Legal – Commercial and Compliance
t: 020 7864 9034 POLICE
e: eray@premierleague.com
In an emergency or if someone is in immediate danger,
call the Police on 999 (101 for non-emergencies).

6
Aims and how we will achieve these
The aims of this Policy are to:

• Outline our commitment, procedures and expectations.

• Promote and achieve the highest safeguarding standards.

• Ensure that there are effective measures in place to assess the

suitability of Staff and Partners.

• Ensure that there are effective measures in place to create and

maintain safe and inclusive environments.

• Ensure that Staff are clear about what constitutes appropriate

behaviour and professional boundaries.

• Ensure that Staff recognise poor practice and abuse and are
empowered to take appropriate action when a safeguarding
concern arises.

7
Safeguarding Policy Season 2019/20 - Aims and how we will achieve these

Getting the right people involved Staff and Partners responsibilities:

Safer recruitment and procurement procedures are an
essential part of safeguarding.
Safer recruitment
 consultancy or third-party capacity.
The Premier League is committed to getting the right
people involved, preventing unsuitable people from
working with Children, Young People and Adults at
Risk, and actively promoting safeguarding within all
partnerships and commissioned services.


We are committed to safer recruitment procedures
which include:
• Ensuring recruiters and interviewers are
appropriately trained and supported.
• Fair and thorough application processes.
✓ Work with our HR and Safeguarding Teams to
ensure all pre-recruitment and suitability checks
have concluded prior to allowing an individual to
commence their role whether in a paid, voluntary,
✓ Work with our Safeguarding Team to assess the
suitability of partners and service providers, and
the adequacy of their safeguarding and safer
recruitment policies and practice.
✓ Work with our Legal and Safeguarding Teams
to ensure that contractual agreements address
safeguarding and that all those involved
understand their respective responsibilities.
✓ Ensure that our safeguarding, recruitment and
procurement procedures are adhered to.

• Pre-recruitment checks which include identity

verification, references and where applicable, Raising awareness
criminal record checks. All Staff and Partners are required to undertake
regular safeguarding education delivered by the
• Role descriptions which accurately record
Premier League at a level appropriate to individual
responsibilities.
roles and responsibilities regardless of their
• Providing effective supervision, training and background or level of expertise.

support.


Our Safeguarding Policy is closely linked with our
Recruitment and Selection Policy.


Partnerships and commissioned services
Propriety and behaviour


This section aims to provide a framework of expected
standards and behaviour that contribute to ensuring
that a safer culture is developed and maintained.

We are committed to actively promoting
safeguarding within all partnerships and
commissioned services by:
• Actively communicating our safeguarding policies
and procedures to partners and service providers.
• Assessing the suitability of partners and service
providers and the adequacy of their safeguarding
and safer recruitment policies and practice.
This is not an exhaustive list of expected and
prohibited behaviours. Staff and Partners are
expected to act in the best interests of Children,
Young People and Adults at Risk and ensure that their
safety and welfare is a primary consideration where
no policy, rules or guidelines exist.

• Ensuring that contractual agreements outline

respective safeguarding responsibilities.

• Working together to protect the safety and

welfare of Children, Young People and Adults at
Risk.

8
Staff and Partners are expected to:
✓ Familiarise themselves with this Policy.
✓ Know who the Safeguarding Team is and how to
contact them.
✓ Ensure the safety of the Children, Young People
and Adults at Risk in their care.
✓ Always act in the best interests of Children, Young
People and Adults at Risk.
✓ Build balanced relationships with Children, Young
People and Adults at Risk based on mutual trust.
✓ Maintain appropriate and professional boundaries
at all times.
✓ Treat all Children, Young People and Adults at Risk
equally, with respect, dignity and fairness.
✓ Ensure that the same professional standards
are applied regardless of ethnic origin, colour,
nationality, race, religion or belief, gender, sexual
orientation, age or disability.
✓ Respect the views, wishes and feelings of Children,
Young People and Adults at Risk.
✓ Recognise the developmental needs of Children
and Young People and capacity of Children, Young
People and Adults at Risk.
✓ Help maintain an ethos whereby colleagues,
partners, Children, Young People and Adults at
Risk and their parents, legal guardians and carers
feel able to express any concerns comfortably and
safe in the knowledge that effective action will be
taken as appropriate.
✓ Promote an environment where poor practice is
challenged and reported.
✓ Ensure that any concerns or allegations pertaining
to the safety and/or welfare of Children, Young
People and Adults at Risk are recorded and acted
upon in accordance with this Policy.
✓ Encourage and demonstrate consistently high
standards of behaviour and understand the types
of behaviour that may call into question their
suitability to work with Children, Young People and
Adults at Risk.
✓ Be aware that behaviour outside of work time may
impact upon their suitability to work with Children,
Young People and Adults at Risk.
✓ Be aware that breaches of the law and this Policy
may result in criminal and/or disciplinary action
being taken against them.
Staff and Partners must never:
✕ 
Use their position of power and influence to
intimidate, threaten, coerce, exploit or undermine
Children, Young People and Adults at Risk.
✕ 
Use their status and standing to form or promote
inappropriate relationships. Professional
boundaries must be maintained at all times. See
page 21 or more information about professional
boundaries.
✕ 
Use their position to gain access to information
relating to Children, Young People and Adults
at Risk for their own or others’ advantage. Such
information should only be used or shared to
protect Children, Young People and Adults at Risk
and to meet their needs.
✕ 
Carry out their duties whilst under the influence of
alcohol, solvents or drugs.
✕ 
Engage in any sexual or related activities, or have
discussions about such activities, in the presence
of Children, Young People and Adults at Risk,
except in a clear educational context and with the
knowledge and agreement of the Premier League/
PLCF.
✕ 
Never use Premier League/PLCF equipment to
access pornography or access pornography on
personal devices when on duty.
✕ 
Access, make or distribute illegal or indecent
content or images of Children or Adults at Risk.
Relationships of trust
Those who have responsibility for, authority or
influence over Children, Young People and/or Adults
at Risk are in relationships of trust in relation to the
Children, Young People and/or Adults at Risk in their
care.
A relationship of trust can be described as one in
which one party has power and influence over the
other by virtue of their work or the nature of the
Activity they are engaged in.
It is important for Staff and Partners to be aware
of the power imbalance inherent in their role with
Children, Young People and/or Adults at Risk and
the responsibility that must be exercised as a
consequence.
Staff and Partners have a responsibility to ensure that
their position and/or influence is not used for personal
advantage or gratification.
9
Recognising and responding to abuse, poor
practice and other safeguarding concerns
Abuse and poor practice could be perpetrated by anyone and
could take place anywhere, for example, in a person's own home,
their community, their peer groups, at school, a hospital or within a
sport activity.



The Premier League and PLCF are committed to making it as

difficult as possible for anyone to be abused, exploited and
mistreated.

Staff are not expected to be experts in recognising abuse, however,

knowledge, understanding and being able to recognise abuse and
poor practice contributes to a safer culture and environment.

10
Physical abuse: Any deliberate act causing injury
or trauma to another person, for example, hitting,
slapping, pushing, kicking, burning, giving a person
medicine that they do not need and/ or that may
harm them or application of inappropriate restraint
measures.
Emotional abuse: Any act or other treatment which
may cause emotional damage and undermine a
person’s sense of wellbeing, including persistent
criticism, denigration or putting unrealistic
expectations on Children, Young People and Adults
at Risk, isolation, verbal assault, humiliation, blaming,
controlling, intimidation or use of threats.
Sexual abuse: Any act which results in the
exploitation of Children, Young People and Adults
at Risk, whether with their consent or not, for the
purpose of sexual or erotic gratification. This includes
non-contact activities, such as indecent exposure,
involving Children, Young People and Adults at Risk
in witnessing sexual acts, looking at sexual images/
pornography or grooming them in preparation for
abuse (including via the internet). Whilst the age of
consent (the age at which a person is considered
to be legally competent to consent to sexual acts)
is sixteen, it is unacceptable for Staff and Partners
to abuse their relationship of trust for sexual
gratification.
Child sexual exploitation: A form of Child sexual
abuse. It occurs where an individual or groups of
people take advantage of an imbalance of power
to coerce, manipulate or deceive a Child or Young
Person into sexual activity in exchange for something
the victim needs or wants and/or for the financial
advantage or increased status of the perpetrator
or facilitator. The victim may have been sexually
exploited even if the sexual activity appears
consensual. Child sexual exploitation can also take
place through the use of technology.
County lines: The organised criminal distribution of
drugs by gangs from the big cities into smaller towns
and rural areas using Children, Young People and
Adults at Risk. Gangs recruit Children, Young People
and Adults at Risk through deception, intimidation,
violence, debt bondage and/or grooming. Gangs also
use local property as a base for their activities, and
this often involves taking over the home of an Adult
at Risk who is unable to challenge them. County line
gangs pose a significant threat to Children, Young
People and Adults at Risk upon whom they rely to
conduct and/or facilitate such criminality.
Cuckooing: Cuckooing is a term often linked to county
lines. Cuckooing is when gangs establish a base in the
location they are targeting for drug dealing and to
operate their criminal activity from, often taking over
the homes of adults at risk by force or coercion.
People exploited in this way will quite often be
exposed to physical, mental and sexual abuse, and
in some instances will be trafficked to areas a long
way from home as part of the network’s drug dealing
business.
Victims of ‘cuckooing’ are often drug users but can
include older people, those suffering from mental or
physical health problems, female sex workers, single
mums and those living in poverty. Victims may suffer
from other forms of addiction, such as alcoholism.
Neglect: Ongoing failure to meet the basic needs
of Children, Young People and Adults at Risk.
Neglect may involve failing to provide adequate
food or shelter including exclusion from home or
abandonment, failing to protect them from physical
and emotional harm or danger or failing to ensure
access to appropriate medical care or treatment. It
may also include neglect of, or unresponsiveness to,
basic emotional needs.
In an Activity setting, it may involve failing to ensure
that Children, Young People and Adults at Risk are
safe and adequately supervised or exposing them to
unnecessary risks.
Grooming: The process of developing a relationship
with and the trust of an individual, and sometimes
their family, to exploit, abuse or traffic them.
Grooming can happen both online and in person.
Radicalisation: The process by which a person
comes to support terrorism and forms of extremism
leading to terrorism. Anybody from any background
can become radicalised. The grooming of Children,
Young People and Adults at Risk for the purposes
of involvement in extremist activity is a serious
safeguarding issue.
Female genital mutilation (“FGM”): Involves
procedures that intentionally alter or injure female
genital organs for non-medical reasons. The
procedure has no health benefits for girls and women.
The Female Genital Mutilation Act makes it illegal to
practise FGM in the UK or to take women and girls
who are British nationals or permanent residents of
the UK abroad for FGM whether or not it is lawful in
another country.
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Safeguarding Policy Season 2019/20 - Recognising and responding to abuse, poor practice and other safeguarding concerns
Bullying: Repeated behaviour intended to
intimidate or upset someone and/or make them
feel uncomfortable or unsafe, for example, name
calling, exclusion or isolation, spreading rumours,
embarrassing someone in public or in front of their
peers, threatening to cause harm, physically hurting
someone or damaging their possessions.
Cyberbullying: The use of technology to harass,
threaten, embarrass, humiliate, spread rumours or
target another person. By definition, it occurs among
Children and Young People. When an adult is the
victim, it may meet the definition of cyber harassment
or cyberstalking.
Discriminatory abuse: Abusive or bullying behaviour
because of discrimination occurs when motivated
by a prejudice against certain people or groups of
people. This may be because of an individual’s ethnic
origin, colour, nationality, race, religion or belief,
gender, gender reassignment, sexual orientation or
disability. Actions may include unfair or less favourable
treatment, culturally insensitive comments, insults and
‘banter’. Discriminatory behaviour is unacceptable
and will be reported to The FA. This includes incidents
on and off the pitch (including social media).
Poor practice: This is behaviour that falls short of
abuse but is nevertheless unacceptable. It is essential
that poor practice is challenged and reported
even where there is a belief that the motives of an
individual are well meaning. Failure to challenge
poor practice can lead to an environment where
abuse is more likely to remain unnoticed. Incidents
of poor practice occur when the needs of Children,
Young People and Adults at Risk are not afforded the
necessary priority, compromising their welfare, for
example, allowing abusive or concerning practices
to go unreported, placing Children, Young People
and Adults at Risk in potentially compromising and
uncomfortable situations, failing to ensure the safety
of Children, Young People and Adults at Risk, ignoring
health and safety guidelines, or giving continued and
unnecessary preferential treatment to individuals.
Hazing: Any rituals, initiation activities, actions or
situations, with or without consent, which recklessly,
intentionally or unintentionally endangers the physical
or emotional wellbeing of Children, Young People and
Adults at Risk.
Peer-on-peer abuse: Children, Young People and
Adults at Risk can be taken advantage of or harmed
by their peers. Peer-on-peer abuse is any form of
physical, sexual, emotional and financial abuse, and
coercive control, exercised between individuals and
within relationships (both intimate and nonintimate).
12
Infatuations: Children, Young People and Adults at
Risk may develop an infatuation with a member of
Staff or Partners who works with them. Such situations
should be handled sensitively to maintain the dignity
and safety of all concerned. Staff and Partners should
be aware that in such circumstances, there is a high
risk that words or actions may be misinterpreted
and that allegations could be made against Staff
and Partners. They should therefore ensure that their
own behaviour is above reproach. Staff and Partners
who become aware that a Child, Young Person or
Adult at Risk may be infatuated with him/her or
with a colleague, should discuss this at the earliest
opportunity with the Safeguarding Team.
Domestic violence or abuse: Any incident or pattern
of incidents of controlling, coercive or threatening
behaviour, violence or abuse between those aged
sixteen or over, who are or have been intimate with
partners or family members regardless of gender or
sexuality. This can encompass, but is not limited to:
psychological, physical, sexual, financial, emotional
abuse and so called ‘honour’ based violence.
Abuse specific to Adults at Risk
The Care Act defines additional types of abuse
related specifically to safeguarding Adults at Risk
which are described below.
Financial or material abuse: Stealing from a
vulnerable person, using them for financial gain,
putting pressure on them about wills, property,
inheritance or financial transactions, misusing or
stealing their property, possessions or benefits. It may
include depriving a person access to their money,
property or assets. Financial abuse is something more
usually related to adults but where professional (and
future professional) footballers are concerned, this is a
significant area of risk.
Modern slavery: Encompasses slavery, human
trafficking, forced labour and domestic servitude.
Traffickers and slave masters use whatever means
they have at their disposal to coerce, deceive and
force individuals into a life of abuse, servitude and
inhumane treatment.
Organisational or institutional abuse: Neglect and
poor care practice within an institution or specific
care setting such as a hospital or care home, or
where care is provided within an Adult at Risk’s own
home. This may range from one-off incidents to
ongoing ill-treatment. It can be through neglect or
poor professional practice as a result of the structure,
policies, processes or practices within an organisation.
Neglect/acts of omission: Ignoring medical,
emotional or physical care needs, failure to provide
access to appropriate health, care and support
or educational services or the withholding of the
necessities of life such as medication, adequate
nutrition and heating.
Self-neglect: Neglecting to care for one’s personal
hygiene, health or surroundings, including behaviour
such as hoarding.

 The Premier League and PLCF will fully support
Signs and indicators
Indications that a Child, Young Person or Adult at Risk
may be being abused can be difficult to recognise.
Some signs and indicators may be explained by
something plausible, for example, bereavement,
sudden absence of a parent or carer, adolescence or
accidental injury.
The presence of one or more signs and indicators
should not be taken as proof that abuse has or is
taking place, however Staff and Partners do not
need evidence to report a concern. A person may
be at increased risk of harm if you fail to report your
concerns.
No single person can have a full picture of a Child,
Young Person’s or Adult at Risk's circumstances. Staff
and Partners should never think that their concerns
are not significant enough to act on.
Staff and Partners should discuss their concerns with
the Premier League's Safeguarding Team.
Signs and indicators of abuse and other safeguarding
concerns described in this section can be found at
Appendix 1.
Responding to disclosures,
safeguarding incidents and concerns
Responding to safeguarding incidents and
concerns
All disclosures, incidents and allegations must be
taken seriously and responded to in line with the
Premier League’s Safeguarding Policy and training.
This includes allegations about non-recent abuse and
allegations made against deceased individuals.
Staff and Partners should contact the Premier League
Safeguarding Team without delay if they witness an
incident or come upon information pertaining to the
safety and welfare of Children, Young People or Adults
at Risk.
Anyone can contact emergency services or make a
referral directly to statutory agencies, particularly if
they are concerned about a Child's, Young Person’s
or Adult at Risk's immediate safety, if they are having
difficulty contacting a member of the Premier League
Safeguarding Team or if they are concerned that
a disclosure or information about a safeguarding
concern has not been acted upon appropriately.
anyone who in good faith reports their concerns
about the safety and welfare of Children, Young
People and Adults at Risk.
What is a disclosure?
A disclosure is the process by which a person starts to
share that they have been abused with others.
This can happen in a variety of ways including:
• Directly: Telling someone what has happened to
them.
• Indirectly: Inadvertently or deliberately
communicating through behaviours, emotions, art,
writing, appearance, inquiries or discussions about
fears, concerns or relationships.
We recognise that it takes extraordinary courage
for someone to go through the journey of disclosing
abuse and we will ensure that appropriate action is
taken to support and protect them.
Responding to a disclosure
Listen
✓ Staff and Partners should give their full attention
to the person disclosing and should keep their
body language open and encouraging.
✓ Staff and Partners should respect pauses and not
interrupt the person disclosing.
✓ Staff and Partners should limit any questioning to
the minimum necessary to seek clarification only.
When seeking clarification, Staff and Partners
should use the language of the person disclosing
to show that it is their experience.
Reassure
✓ Staff and Partners should provide reassurance
that the person disclosing is being taken seriously
and that they are not to blame.
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Safeguarding Policy Season 2019/20 - Recognising and responding to abuse, poor practice and other safeguarding concerns
Views and wishes
✓ Staff and Partners should engage the person
disclosing as far as possible about how best to
respond to their safeguarding situation.
✓ Staff and Partners are expected to act in the best
interests of Children, Young People and Adults
at Risk. Seek advice from the Premier League
Safeguarding Team without delay if in any doubt
about what action to take, including sharing
information.
Safety
✓ Staff and Partners should ensure that the
immediate needs of the person disclosing are met
and should prioritise their safety and protection
above all else. This may involve contacting
emergency services and/or statutory agencies.
The Premier League’s Safeguarding Team must be
immediately notified of all such action.
Take action
✓ Staff and Partners should explain to the person
disclosing what action they will be taking and that
they will support them through the process. There
may be circumstances where it is not appropriate
to explain the actions that will be taken, for
example, a child's age and understanding or if
doing so would place the person at greater risk of
harm.
✓ Staff and Partners should refer details of the
disclosure to the Premier League’s Safeguarding
Team.
✓ Where it is suspected that a crime has been
committed, the police should be contacted
immediately, and physical, forensic and other
evidence must be preserved.
Record
✓ Good record keeping is essential safeguarding
practice. It is vital that Staff and Partners make a
written record as soon as possible after the person
has disclosed, their immediate needs have been
met and the appropriate referrals have been
made.
Staff and Partners should contact the Premier League
Safeguarding Team if in doubt about recording
requirements.
Staff and Partners must never:
✕ 
Make ambitious promises or promise confidentiality.
14
✕ 
Seek details beyond those the person willingly
discloses.
✕ 
Ask leading questions.
✕ 
Give the impression that the person disclosing is to
blame.
✕ 
Approach the alleged perpetrator of abuse or
person whose behaviour and/or actions there are
concerns about.
 he flowcharts in Appendix 3 outline the steps to
T
be taken by Staff and Partners when dealing with a
disclosure, safeguarding incident or allegation.

Recording information
All incidents, allegations and disclosures must be
recorded on a Premier League Safeguarding Referral
Form which can be found at Appendix 2. If Staff and
Partners are unable to access our Safeguarding
Referral Form, a written record should include the
following information:
• 
Provide a factual account of what you have
observed or have been told.
• 
The date and time of what you have witnessed or
been told.
• 
Details of those involved: (i) person(s) whose
safety and welfare there are concerns about, (ii)
alleged perpetrator of abuse or person(s) whose
behaviour or actions there are concerns about, (iii)
witnesses and (iv) any third party who has raised
concerns.
• 
Action taken and your rationale for taking these
actions.
• 
Date and time of referring the information and to
whom the information was referred.
• 
Your details as the referrer.
Staff and Partners are expected to:
✓ Provide clear, concise and relevant information.
✓ Record information in an objectional and
professional manner.
✓ Record factual information rather than assumption
of what you have witnessed or been told.
✓ Record actual words and language. Don’t rephrase
what you have been told or leave things like insults
or intimate vocabulary out.
✓ Record observations, for example, a description
of visible bruising or injuries. Never ask someone
to remove or adjust their clothing to observe any
bruises, marks or injuries.
If more information is recalled at a later date, this
should be added as an addendum. The original record
must not be changed.
Staff and Partners should be aware that such records
may be used as evidence for investigations and
inquiries, court proceedings, disciplinary procedures
and/or quality assurance purposes.
Therapist appointments
Staff and Partners experiencing mental health
issues can access face to face appointments with a
therapist at our local partner Clinic. Staff and Partners
confidentiality as a patient will be protected and not
shared anywhere.
Staff and Partners can access further details about
the support available to them via the Premier League
Intranet and our HR Team.


Consultants, volunteers and partners

Confidentiality Consultants, volunteers and partners can contact our

All disclosures, safeguarding incidents and allegations
must be taken seriously, and every effort should be
made to ensure that confidentiality is maintained for
all concerned.
HR Team for support with signposting and accessing
support.
Mind provide advice and support to anyone
experiencing a mental health problem.

Those who need to know are those who have specific

responsibilities to support and protect the Child,
Young Person or Adult at Risk and others who may be
at risk, for example, statutory agencies, the Premier
League Safeguarding Team, The FA, parents and
carers. e: HR@premierleague.com 

t: 020 7864 9000 and ask to speak to a member of the
HR Team
Communication and media protocols
All media enquiries and communication with
Clubs, CCOs and other stakeholders following a
safeguarding incident or about our safeguarding
provision generally must be approved by our
Communication and Safeguarding Teams.
https://www.mind.org.uk/

Support for Staff and Partners

Dealing with a disclosure or a safeguarding incident
may have an impact on the wellbeing of those
involved. It is important that anyone affected seeks
help if they feel that they need support.

Premier League employees

Employee assistance programme

Staff and Partners can access this independent and

confidential professional support service which offers
24/7 telephone counselling.

15
Managing safeguarding concerns
Working together underpins our work to effectively safeguard Children,
Young People and Adults at Risk.

We are committed to working in partnership with The FA, Clubs, CCOs,

statutory agencies and other key partners to safeguard Children,
Young People and Adults at Risk. By working together, we create a
culture where safeguarding responsibilities and procedures for creating
safe environments and raising concerns are widely understood and
embedded in our values and practices.

While this Policy applies to Premier League and PLCF Staff, this section
and accompanying flowcharts in Appendix 4 set out how safeguarding
concerns are managed across the game, including thresholds for
external referral and the roles of key stakeholders.

Our Safeguarding Policy is closely linked with our Managing Allegations

against Staff Policy.

16
Football’s safeguarding framework
• The FA sets the safeguarding policy and regulatory
framework across the game.
• The Premier League and PLCF have safeguarding
policies and procedures in place that govern their
own Activities, as well as rules and requirements
that govern Club and CCO safeguarding
arrangements.
• Clubs and CCOs implement their own safeguarding
policies and procedures that must be consistent
with football regulations, legislation, statutory
guidance and current best practice.
Employer role
Premier League, PLCF, Club or CCO as the employer
of an individual whose conduct or behaviour there
are concerns about
Low level poor practice concerns that do not meet
the threshold for external referral are dealt with in line
with internal employer policies and procedures. Where
the threshold for external referral is met, there may
be collaboration with statutory agencies and/or the
Football Authorities.
See flowchart 1 in Appendix 4.
Football Authorities
Premier League and/or PLCF acting in a regulatory
capacity
When in receipt of a referral from a Club or CCO, action
may include:
• Providing support and guidance.
• Having oversight and working with Clubs/CCOs
to ensure that internal procedures and football
regulations are followed.
• Agreeing a Club/CCO-led internal investigation
with the outcome shared with the Football
Authorities.
• Conducting a joint investigation with The FA.
• Commissioning an independent case review
(possibly in conjunction with The FA).
• Participation in multi-agency strategy meetings.
• Working with Clubs/CCOs to implement agreed
multi-agency strategy meeting actions.
• Working with Police and football media relations to
manage communication.
• Issuing of sanctions against Clubs/CCOs where
Premier League Rules and/or PLCF requirements
have been breached.
• Suspension or termination of CCO grant payments
by the PLCF.
• Working with Clubs/CCOs to ensure that learning
outcomes are implemented to mitigate risk of
recurrence.
• Sharing anonymised learning from cases to
strengthen safeguarding provision across the
game.
The FA
The FA has a team made up of safeguarding
professionals who manage referrals. Where
appropriate, they work in partnership with statutory
authorities, the DBS, County FAs, the Premier League
and football clubs when managing safeguarding
cases. They assess people who pose, or may pose, a
risk of harm and put in place safeguards.
The FA's regulatory framework enables them to take
action against any affiliated person or organisation
that breaches their safeguarding regulations and
policies. On an individual level, The FA can put in place
risk management measures ranging from education,
mentoring and supervision agreements, to interim and
permanent suspensions.
Thresholds for referral to Football Authorities
A referral must be made to the Football Authorities
within 24 hours (or as soon thereafter as practicable)
where any of the following thresholds are met:
• Any referral to or from any external authority
(including, without limitation; the Police, Local
Authority, DBS or Charity Commission) about
abuse a Child, Young Person or Adult at Risk by any
current, prospective or former employee, volunteer
or consultant of the Premier League, PLCF, a Club or
CCO. This includes allegations of non-recent abuse.
• A third or subsequent allegation of poor practice
in relation to a Child, Young Person or Adult at
Risk by any employee, volunteer or consultant of
the Premier League, PLCF, a Club or CCO, whether
similar in nature or otherwise.
• Any allegation or information about abuse of
a Child, Young Person or Adult at Risk by a Club
academy player or CCO participant/beneficiary.
17
Safeguarding Policy Season 2019/20 - Managing safeguarding concerns
Statutory agencies
Children and Young People
The Police should be contacted if a crime has been
committed against a Child/Young Person or if a Child/
Young Person is in immediate danger.
A referral should be made to the Local Authority
Designated Officer (LADO) where an individual has:
• Behaved in a way that has harmed, or may have
harmed a Child/Young Person;
• Possibly committed a criminal offence against or
related to a Child/Young Person; or
• Behaved towards a Child/Young Person in a way
that indicates they may pose a risk of harm.
The LADO is responsible for management and
oversight of all Child protection allegations made
against Staff and Partners and volunteers who work
with Children/Young People.
Adults at Risk
The Police should be contacted if a crime has been
committed against an Adult at Risk and/or if an Adult
at Risk is in immediate danger.
A referral should be made to Adult Social Care where
an individual has:
• Behaved in a way that has harmed, or may have
harmed an Adult at Risk;
• Possibly committed a criminal offence against or
related to an Adult at Risk; or
• Behaved towards an Adult at Risk in a way that
indicates they may pose a risk of harm.
Disclosure and Barring Service
The duty to refer to the DBS is met when an employer
has dismissed or removed a person from regulated
activity (defined in the Safeguarding Children, Young
People and Adults at Risk Act as amended by the
Protection of Freedoms Act) or would or may have if
the person had not left, resigned, retired, been made
redundant or moved to another position because the
person has:
• Been cautioned or convicted for a ‘relevant
offence’. A ‘relevant offence’ for the purposes
of referrals to the DBS is an offence that would
result in the individual’s automatic inclusion in the
Children’s or adults’ barred list.
• Engaged in ‘relevant conduct’. ‘Relevant conduct’
18
is that which endangers or is likely to endanger
Children, Young People and Adults at Risk.
• Satisfied the ‘harm test.’
The ‘harm test’ is met when an employer believes that
an individual may harm, may cause to be harmed, may
put at risk of harm, may attempt to harm or may incite
another person to harm a Child, Young Person or Adult
at Risk.
Referrals to the DBS should be made once
investigations and disciplinary processes are complete
(even if the person has left employment). Referrals
must be made even if a significant period has passed
between the allegation and the gathering of evidence
to support a decision to make a referral.
Charity Commission
The Charity Commission is the statutory regulator of
charities in England and Wales. The PLCF and CCOs
are required to report serious incidents, which include
safeguarding issues, to the Charity Commission.
Government guidance states that if a serious incident
takes place, a charity needs to report what happened
and explain how they are dealing with it, even if they
have reported it to the police, donors or another
regulator.
The Charity Commission’s priority is to ensure
that Trustees meet their legal requirements and
obligations. Where there has been abuse or non-
compliance, the Charity Commission may require
corrective action to be taken by the trustees, including
directing them to take action or certain actions.
The Charity Commission takes enforcement action
against charities in a variety of ways. This includes
regulatory action taken during investigations and its
other regulatory work into individual charities. When
the Charity Commission has opened an investigation,
it may use its temporary and/or permanent powers of
protection.
The Charity Commission’s powers include (amongst
others):
• Requiring corrective action be taken by Trustees.
• Agreeing an action plan for the charity.
• Undertaking checks to monitor action taken by the
charity.
• Referring concerns to statutory authorities and/
or to specialist bodies responsible for designated
areas, such as education or health and social care.
• Restricting the transactions that a charity may
enter into.
• Appointing additional Trustees.
• Freezing a charity’s bank account.
• Suspending or removing a Trustee.
• Appointing an interim manager.
Thresholds for referrals to the Charity Commission
A referral should be made to the Charity Commission
where the following thresholds are met:
• Any incident that results in significant harm to
Children, Young People and/or Adults at Risk.
• A breach of the PLCF’s or a CCO’s policies or
procedures that puts Children, Young People and/
or Adults at risk of harm.
• Failure to carry out checks which would have
identified that a person is disqualified in law,
under safeguarding legislation, from working with
Children, Young People or Adults at Risk.
• Any allegation of abuse of a Child, Young Person
and/or Adult at Risk while under the care of the
PLCF or a CCO, or by someone connected to the
PLCF or a CCO, for example, a Trustee, employee,
volunteer, consultant or other person who comes
into contact with the PLCF or a CCO through its
work.
Making a referral to the Charity Commission
Responsibility for reporting serious incidents rests
with a charity’s Trustees but in practice this may be
delegated to someone else within the charity, such
as an employee. If a PLCF or CCO Trustee is reporting
the incident, they will need to confirm that they have
authority to report on behalf of the Trustee Body.
Where the threshold for referral to the Charity
Commission is met, a report should be made by
emailing RSI@charitycommission.gsi.gov.uk with the
following information:
• Details of the individual making the report and
their connection to the PLCF or CCO.
• Confirmation that the individual making the report
has the authority to do so.
• Details of who in the Trustee Body is aware of the
incident, for example, all or only the Chair.
• Details of the incident or allegation and when the
PLCF or CCO first became aware of the issue.
• Details of what action has and/or is being taken to
deal with the incident or allegation.
• Details of what measures have and/or will be
implemented to mitigate risk of recurrence.
• Details of whether and when the incident or
allegation has been reported to statutory agencies
and/or the Football Authorities or any other
specialist/regulatory bodies.
Further information about all reportable incidents and
how to report a serious incident can be found via the
following webpage: www.gov.uk/guidance/how-to-
report-a-serious-incident-in-your-charity
Further guidance on safeguarding issues in charities
can be found via the following webpage: www.gov.uk/
government/publications/strategy-for-dealing-with-
safeguarding-issues-in-charities
Data protection
We will maintain confidentiality of all; (i) data
collected (in writing or electronically) relating
to Children, Young People and Adults at Risk,
(ii) information and documentation relating to
safeguarding allegations, concerns and incidents,
and (iii) information and documentation relating to
recruitment and selection procedures in accordance
with relevant data protection legislation.
Listening culture
We are committed to ensuring that safeguarding is
person-led and outcome-focused. We will engage
Children, Young People and Adults at Risk about how
best to respond to their safeguarding situation in a
way that enhances involvement, choice and control as
well as improving wellbeing and safety.
We believe that Children, Young People and Adults
at Risk have the right to be heard and involved in
decisions that affect them. The Premier League and
PLCF will always act in the best interests of Children,
Young People and Adults at Risk and we will seek their
views (and in the case of a Child/Young Person, the
views of their parents/guardians where appropriate)
as far as is feasible taking their age, understanding
and capacity into account when responding to
disclosures and safeguarding concerns.
In the absence of consent from an individual making
a disclosure or to whom the information relates, we
will take proportionate action that does not increase
the risk of harm. This may include sharing information
where there is an overriding duty to do so for
legitimate purposes.
19
Safer working practices
Good safeguarding practices protect everyone.

This section aims to inform Staff about practices that contribute to a

safer culture and environment. Whilst every attempt has been made
to cover a wide range of activities in this section, it is recognised that it
cannot cover all eventualities.

Staff are expected to make judgements about their actions and

behaviour to secure the best interests and safety of the Children, Young
People and Adults at Risk in their care. All actions and behaviours
should be guided by the principle that the safety and welfare of
Children, Young People and Adults at Risk is paramount.


20
Maintaining professional boundaries
Working with Children, Young People and Adults at
Risk may involve physical contact, such as medical
intervention, responding to success or distress,
preventing an injury or accident, sporting skills
instruction or demonstrating the safe use of a piece of
equipment.
There may be some roles where physical contact
is commonplace and/or a requirement of the role,
particularly in sports science or medicine. These tasks
should only be undertaken by properly trained and
qualified practitioners. This Policy does not seek to
replace the specific guidance and codes of practice
developed for those professionals.
Children, Young People and Adults at Risk are entitled
to respect and privacy at all times, particularly when
in a state of undress, changing clothes, showering or
undertaking any form of personal care. All supervision
measures should be transparent, consistently applied
and appropriate to the needs, age and capacity of
those concerned.
Staff and Partners should never assist with personal
care tasks that can be undertaken independently
and any such assistance must form part of an agreed
Premier League or PLCF care plan.
Engaging in sexual activity or an intimate relationship
with a Child, Young Person or Adult at Risk with whom
Staff and Partners come into contact through their
role will be considered a breach of trust leading to
a referral to the appropriate authorities. In some
circumstances, such a breach may also constitute a
criminal offence.
Sexual activity does not just constitute physical
contact. It may also include non-contact activities,
such as causing Children, Young People and Adults
at Risk to engage in or watch sexual activity or
producing pornographic material.
In all circumstances where a Child, Young Person or
Adult at Risk initiates inappropriate contact, it is the
responsibility of the member of Staff or Partner to
sensitively deter them and help them understand
the importance of personal boundaries. Should
inappropriate contact be initiated by a Child, Young
Person or Adult at Risk, then it must be recorded and
reported to the Premier League Safeguarding Team.
In addition, if a member of Staff or a Partner believes
their own actions could be misinterpreted or they
observe an action or behaviour by another member
of Staff or a Partner that could be considered to be
inappropriate or possibly abusive, the incident and
circumstances should also be recorded and reported
to the Premier League Safeguarding Team.
Communication
Good communication is central to working with
Children, Young People and Adults at Risk, however
all communication by whatever method should take
place within professional boundaries. This includes the
wider use of technology, for example, mobile phones,
email and social media.
Staff and Partners are expected to:
✓ Build respectful and trusting relationships with
Children, Young People and Adults at Risk.
✓ Only contact Children, Young People and Adults
at Risk, for professional reasons and with the
knowledge and agreement of the Premier League/
PLCF.
✓ Maintain professional boundaries at all times.
Staff and Partners must never:
✕ 
Intimidate, threaten, coerce, exploit or undermine
Children, Young People and Adults at Risk.
✕ 
Use offensive, abusive or inappropriate language.
✕ 
Share any personal information or contact details
with Children, Young People and Adults at Risk.
✕ 
Request any personal information from Children,
Young People and Adults at Risk without the
knowledge and agreement of the Premier League/
PLCF. The Premier League and PLCF must be
aware of all personal data processed.
Creating a safe environment
We believe that the safety, welfare and enjoyment of
Children, Young People and Adults at Risk should be
a primary consideration during the planning, delivery
and review of all our Activities.
These key considerations are not exhaustive, however
they do give Staff and Partners a good framework to
build from when planning and delivering Activities:
• 
Experience and suitability of the Staff and Partners
involved.
• 
Assessing the suitability of partners and service
providers and the adequacy of their safeguarding
and safer recruitment policies and practices.
• 
Ensuring that contractual agreements outline
21
Safeguarding Policy Season 2019/20 - Safer working practices

respective safeguarding responsibilities. the Children, Young People and Adults at Risk
participating.
• 
Health, safety and safeguarding risks should
be identified and mitigated. Pre-activity and • 
The competence and experience of Staff and
dynamic risk assessments should be undertaken by Partners involved.
competent Staff and Partners.
• 
The nature and duration of the Activity.
• 
Safe travel and transport arrangements.
• 
Risk assessments and/or intelligence identifying
• 
Ensuring that accommodation is in a safe location, potential behavioural or other issues and risks.
is safely managed and is of good standard for
security, hygiene and first aid. Staff and Partners must work with the Premier
League Safeguarding Team when planning Activities
• 
Emergency response procedures covering injury, to ensure that appropriate ratios and supervision
illness, emergency evacuation, safeguarding arrangements are carefully considered.
concerns, missing persons, local services and
emergency contacts including emergency consular
assistance details when abroad. Lone working and one-to-one situations
A lone worker, for the purpose of this Policy, is defined
• 
Ensuring that there is adequate insurance cover in
as a member of Staff or a Partner who is engaged
place.
in activities which place them in a situation without
• 
Consent for participation, emergency medical direct contact with other Staff and Partners or
treatment and the use of images/footage. without direct supervision.

• 
Appropriate supervision arrangements and ratios. Staff and Partners responsibilities:

• 
Ensuring that additional vulnerability and needs ✓ Work in an open and transparent way and avoid
are carefully considered. conduct which could raise concern or place
Children, Young People and Adults at Risk of harm.
• 
Codes of conduct for Children, Young People and
Adults at Risk, Staff and Partners and spectators. ✓ Under no circumstances should Staff and Partners
visit Children, Young People and Adults at Risk in
• 
Procedures for dealing with challenging behaviour
their homes outside agreed work arrangements.
and bullying.
Nor should they invite Children, Young People and
• 
Security and measures to manage the behaviour Adults at Risk to their own home or to that of a
of spectators. family member, colleague or friend.

• 
Safe dispersal procedures. ✓ Ensure that contact by whatever means and
meetings with Children, Young People and Adults
Working together is an underpinning principle of at Risk outside agreed working arrangements
safeguarding. Staff and Partners must consult with never take place without the knowledge and
the Premier League Safeguarding Team at the early
agreement of the Premier League/PLCF.
planning stages of all Activities for support and to
ensure that safeguarding risks specific to each Activity
are fully considered and appropriately managed prior Gifts, rewards and selection
to delivery. 

Staff and Partners should exercise care when
selecting Children, Young People and Adults at
Supervision and ratios Risk for activities, privileges or rewards to avoid
perceptions of favouritism or unfairness. Methods and
Staff and Partners are expected to provide
criteria for selection should always be transparent
appropriate supervision of the Children, Young People
and consistently applied with the knowledge and
and Adults at Risk in their care at all times. The level
agreement of the Premier League/PLCF. Care should
of supervision required will vary between activities.
also be taken to ensure that Staff and Partners do not
Ratios for each Activity should be determined by
accept any gift that might be construed as a bribe
taking the following into consideration:
by others or lead the giver to expect preferential
• 
The age, needs, abilities and behaviour of treatment.

22
Behaviour management
Children, Young People and Adults at Risk have a right
to be treated with respect and dignity at all times,
even in circumstances where they display difficult or
challenging behaviour.
Children, Young People and Adults at Risk must never
be subject to any form of treatment that is harmful,
abusive, humiliating or degrading.
All measures for dealing with difficult or challenging
behaviour must be deployed with the knowledge and
agreement of the Premier League/PLCF.
Children and Young People: Parents/guardians of
Children and Young People should be informed where
behaviour management measures are deployed.
Adults at Risk: Carers may be informed, where
appropriate, with the consent of the Adult at Risk.
Photography and video footage
Photography and video footage includes the taking
of still photographs, filmed and moving images and
video recordings by whatever means.
We will ensure that photography and video footage
is only be taken and used where it is necessary and
legitimate to do so and with the appropriate consent.
to give a lift may place them at risk of harm, must
be immediately reported to the Premier League
Safeguarding Team. In the case of a child, parent/
legal guardian consent should also be sought where
possible.
Staff and Partners responsibilities:
✓ Only transport Children, Young People and Adults
at Risk if it is part of your role and responsibilities.
Staff and Partners must ensure that emergency
arrangements are justified, reported and recorded.
✓ The safety and welfare of Children, Young People
and Adults at Risk must underpin Staff and
Partners behaviour and actions.
✓ Ensure that the vehicle is roadworthy,
appropriately insured and that the maximum
capacity is not exceeded.
✓ Ensure that all arrangements for vehicle,
passenger and driver safety are in place, including
appropriate licence and insurance documents.
✓ Staff and Partners must be fit to drive and free
from any drugs, alcohol or medication that is likely
to impair their judgement or ability to drive.
✓ Children, Young People and Adults at Risk should
occupy the back seats.

Staff and Partners must work with the Premier League ✓ Ensure seatbelts are working and are always used.
Safeguarding and Legal Teams when planning for the
taking and use of photographs and video footage to First aid and administration of medication
ensure that our Safeguarding and Data Protection
Policies are adhere to. In circumstances where a Child, Young Person or Adult
at Risk needs medication regularly, a Premier League
Staff and Partners must never: or PLCF health care plan should be established to
ensure the safety and protection of Children, Young
✕ 
Take, display or distribute photographs or video
People and Adults at Risk and the Staff and Partners
footage of Children, Young People and Adults at
who are working with them.
Risk without the knowledge and agreement of the
Premier League/PLCF. When administering first aid, Staff and Partners
should ensure that another adult is aware of the
✕ 
Share photographs or video footage of the
action being taken wherever possible. Staff and
Children, Young People and Adults at Risk their
Partners should understand the extent and limitations
role brings you into contact with on private social
of their role and should recognise when an injury
or professional media accounts, for example,
requires more experienced intervention.
Instagram, Facebook or LinkedIn.
Children and Young People: Parents/legal guardians
should always be informed when first aid has been
Transport
administered.
It is not appropriate for Staff and Partners to
transport Children, Young People and Adults at Risk Adults at Risk: Carers may be informed, where
outside of their normal working duties. Any occasion appropriate, with the consent of the Adult at Risk.
where a Child, Young Person or Adult at Risk requires
transport in an emergency situation or where not

23
Safeguarding Policy Season 2019/20 - Appendices

Appendices
Appendix 1: Possible signs and indicators of abuse, bullying and other
safeguarding concerns

The possible signs and indicators detailed in this • Untreated injuries

Appendix are not exhaustive, however they can
• Injuries found at different states of healing
assist in identifying abuse, bullying and other
safeguarding concerns. • Injury shape similar to an object

• Refusal to discuss injuries

Common signs and indicators of abuse
and bullying • Arms and legs kept covered in hot weather

• L
 osing interest or dropping out of positive activities • Fear of medical help
or activities they once enjoyed
• Delays in physical development
• S
 ubdued or changed behaviour in the presence of
a particular individual(s) • D
 rowsiness due to too much medication or lack of
medication
• C
 hanges in eating habits or developing an eating
problem
Emotional abuse
• Sudden weight change
• Isolation
• Sudden changes in behaviour
• Fear of making mistakes
• Sudden changes in performance
• Over meticulous
• Not being able to concentrate or focus
• Becoming withdrawn, agitated and/or anxious
• Alcohol and/or substance misuse
• Tearfulness
• Isolation from family, peers and/or social networks
• Unexplained paranoia or excessive fears
• Self-harm or suicide attempts
• Low self-esteem
• Becoming withdrawn
• Struggling to control their emotions
• Depression
• Have difficulty making or maintaining relationships
• Anxiety
• Lack of growth or development
• Sleep disorders
• Unexplained speech disorders

• Lack social skills

Physical abuse
• U
 nexplained marks, injuries, burns or scalds, bite • Having few or no friends
marks, loss of hair in clumps, broken or fractured
• A
 cting or dressing inappropriate for age, gender
bones
and/or culture
• Recurrent injuries

• A history of unexplained falls, or minor injuries Sexual abuse

• G
 enital and stomach pain, itching, bruising,
• Inconsistent accounts for the cause of injuries
discharge and bleeding, pregnancy, incontinence,
• Injuries not consistent with the explanation given repeated urinary infections and sexually-
for them transmitted infections

24
• Difficulty walking or sitting • Being found out-of-area

• H
 aving inappropriate knowledge of sexual
behaviour for their age
• A preoccupation with anything sexual
• Starting to use new or unknown slang words
• S
 tarting to adopt certain codes of group behaviour
e.g. ways of talking and hand signs

• Inappropriate or unusual changes in the way • U

 nexplained physical injuries, and/or refusal to
affection is shown seek or receive medical treatment for injuries

• D
 isplaying inappropriate sexualised behaviour, • Excessive receipt of texts and/or phone calls
such as dressing in a sexualised manner or sending
sexualised images by mobile phone (“sexting”) • Graffiti style ‘tags’ on possession

• Having nightmares • C
 onstantly talking about another person who
seems to have a lot of influence over them
• Bed-wetting
• B
 reaking contact with old friends and hanging
around with one group of people
Child Sexual Exploitation
• Gang association
• U
 nexplained gifts, money or possessions they can’t
or won’t explain • A
 ssociating with known or suspected gang
members, closeness to siblings or individuals in the
• G
 oing missing for periods of time or regularly family who are gang members
returning home late
• E
 xpressing aggressive or intimidating views
• Skipping school or being disruptive towards other groups of, some of whom may have
been friends in the past
• G
 enital and stomach pain, itching, bruising,
discharge and bleeding, pregnancy, incontinence, • B
 eing frightened of certain people, places or
repeated urinary infections and sexually- situations
transmitted infections
• Relationships with controlling individuals or groups
• H
 aving inappropriate knowledge of sexual
behaviour for their age • Carrying weapons

• A preoccupation with anything sexual

Cuckooing
• Inappropriate or unusual changes in the way
affection is shown • A
 n increase in people entering and leaving their
property
• B
 eing frightened of certain people, places or
situations • An increase in cars or bikes outside the property

• Being secretive • Increasing litter outside the property

• S
 udden changes in their appearance and wearing • Possible increase in anti-social behaviour
more revealing clothes • Signs of drugs use
• S
 igns of unexplained physical harm, such as • Lack of healthcare visitors
bruising and cigarette burns
• C
 hange in mood and/or demeanour, for example,
being secretive, becoming withdrawn, aggressive
County lines or emotional
• U
 nexplained gifts, money or possessions they can’t
• Unexplained, sometimes unaffordable new things
or won’t explain
• Unexplained injuries
• G
 oing missing for periods of time or regularly
returning home late • Substance misuse and/or drug paraphernalia

• Persistently going missing from school or home

25
Safeguarding Policy Season 2019/20 - Appendices

Neglect Radicalisation
• Poor hygiene Vulnerability

• Looking unkept • Identity crisis - Distance from cultural or religious

heritage and uncomfortable with their place in the
• Being smelly or dirty society around them
• Frequent tiredness • P
 ersonal crisis - Family tensions or trauma,
• Being hungry or not given money for food sense of isolation, adolescence, low self-esteem,
disassociating from existing friendship group and
• Malnutrition becoming involved with a new and different group
of friends, searching for answers to questions
• Having unwashed clothes
about identity, faith and seeking a sense of
• Ill-fitting or inappropriate clothing such as no belonging
warm clothes in winter
• P
 ersonal circumstances - Migration, local
• Stealing food and/or money community tensions, events affecting country or
region of origin, alienation from UK values, having
• Being left alone for a long time a sense of grievance that is triggered by personal
experience of racism or discrimination or aspects
• Being withdrawn, depressed or anxious
of Government policy
• F
 inding it hard to concentrate or take part in
• U
 nmet aspirations - Perceptions of injustice, feeling
activities
of failure, rejection of civic life
• Untreated injuries and medical problems
• C
 riminality - Experiences of imprisonment,
• P
 arents or carers absent or unsupportive or poor resettlement or reintegration or previous
disengaged involvement with criminal groups

• E
 xperience of poverty, disadvantage,
Grooming discrimination or social exclusion

• B
 eing very secretive about how they’re spending • L
 earning difficulties and mental health support
their time, including when online needs

• Isolation – not seeing friends and family • E

 xperienced personal trauma, particularly any
trauma associated with war or sectarian conflict
• H
 aving money or new things like clothes and
mobile phones that they can’t or won’t explain
Behaviours
• Being upset, withdrawn or distressed
• U
 sing extremist narratives and a global ideology to
• S
 exualised behaviour, language or an
explain personal disadvantage.
understanding of sex that’s not appropriate for
their age, understanding and/or culture • Justifying the use of violence to solve societal issues

• S
 pending more time away from home or going • S
 ignificant shift in behaviour or outward
missing for periods of time appearance that suggests a new social, political,
or religious influence
• T
 hey start talking about a new friend, girlfriend,
boyfriend or partner and it’s not clear who they are • C
 onflict with family over religious beliefs, lifestyle or
or how they met them dress choices

• A child having an older boyfriend or girlfriend • V

 ocal support for terrorist attacks (either verbally
or written)
• Underage drinking or drug taking
• W
 itnessed or been the perpetrator or victim of
Grooming can also lead to radicalisation.
racial or religious hate crime

26
• T
 ravel for extended periods of time to international FGM
locations known to be associated with extremism
• Difficulty walking, sitting or standing
• C
 hange in emotional behaviour, for example,
• S
 pending longer than normal in the bathroom or
becoming withdrawn or angry
toilet
• S
 haring of views or trying to influence others with
• difficulties urinating or incontinence
extremist ideology
• Unusual behaviour after a lengthy absence
• Ignoring or demonising viewpoints that contradict
their own • R
 eluctance to undergo normal medical
examinations
• E
 xpressing themselves in an ‘us vs. them’ manner
about others who have alternative beliefs • A
 sking for help, but may not be explicit about the
problem due to embarrassment or fear
• Increasingly secretive or unwilling to discuss views
Possible warning signs that FGM might be about to
• Changing their circle of friends
take place are:
• Losing interest in activities they once enjoyed
• A
 planned summer trip to a country known to
• B
 ecoming socially withdrawn or spending a lot of practise FGM
time online
• T
 alk about visiting relatives for a special procedure,
• S
 ecretive about who they talk to online and which ceremony or event
websites they visit
• Mention of a female relative coming to visit
• B
 elief in conspiracy theories and distrust of
• A
 sking for help from a trusted adult if she feels at
mainstream media
risk of danger
• J ustifying the use of violence or expressing a desire
• R
 eferencing FGM, female circumcision, cutting or
for revenge
it’s other alternative names listed in the National
FGM Centre’s guidance: http://nationalfgmcentre.
Access to extremism/extremist influences org.uk/wp-content/uploads/2018/02/FGM-
Terminology-for-Website.pdf
• A
 ssociation with extremist groups, associates or
family engaging in extremist activity • A
 holiday that includes additional time away
before, or at the end of, the summer holidays,
• A
 ccessing the internet for the purpose of extremist encroaching on school time
activity, for example, use of closed network groups,
access to or distribution of extremist material, • T
 he family making preparations to take the girl
contact associates covertly via online measures, for abroad ‘on holiday’ e.g. arranging vaccinations or
example, Skype and email requesting a prolonged absence from school

• P
 ossesses or is actively seeking to possess and/
or distribute extremist literature or other media Bullying
material likely to incite racial, religious hatred or • S
 udden loss of friends or avoidance of social
acts of violence. situations
• S
 upport for groups with links to extremist activity, • B
 eing frightened of certain people, places or
for example, propaganda distribution, fundraising situations
and attendance at meetings
• Unexplainable injuries
• E
 xtremist ideological, political or religious influence
from within or outside UK • Lost or destroyed clothing of property

• F
 requent headaches or stomach aches, feeling sick
or faking illness

27
Safeguarding Policy Season 2019/20 - Appendices

• C
 hanges in eating habits, like suddenly skipping • S
 pending more or less time online or on their
meals or binge eating. devices

• Difficulty sleeping or frequent nightmares • S

 pend a lot more or a lot less time than usual
online, texting, gaming or using social media
• D
 eclining grades, loss of interest in schoolwork, or
not wanting to go to school • S
 eem distant, upset or angry after using the
internet or texting
• S
 udden loss of friends or avoidance of social
situations • B
 e secretive about who they’re talking to and
what they’re doing online or on their mobile phone
• Feelings of helplessness or decreased self-esteem
• H
 ave lots of new phone numbers, texts or email
addresses on their mobile phone, laptop or tablet
Domestic violence
• Appear controlled by their phone
Witness to domestic abuse
• S
 witch to a new screen when someone comes near
• Aggression or bullying
the computer
• Anti-social behaviour, like vandalism
• Upset or frustrated after going online or gaming
• Anxiety, depression or suicidal thoughts

• Attention seeking Abuse specific to adults at risk

• Bed-wetting, nightmares or insomnia
Financial or material signs
• C
 onstant or regular sickness, like colds, headaches
• B
 eing unable to afford a new kit, appear to be
and mouth ulcers
hungry or mention being unable to bills

• U
 nexplained lack of money or inability to maintain
Victim of domestic abuse
lifestyle

• Low self-esteem • D
 isparity between assets and satisfactory living
conditions
• P
 hysical evidence of violence such as bruising, cuts,
broken bones • S
 igns of financial hardship in cases where the
person’s financial affairs are being managed by a
• E
 xhibits excessive privacy concerning their
court appointed deputy, attorney or LPA
personal life or the person with whom they’re in a
relationship • E
 xtraordinary interest by family members and
other people in the person’s assets
• V
 erbal abuse and humiliation by their partner in
front of others • T
 he person allocated to manage financial affairs is
evasive or uncooperative
• F
 eeling anxious and stressed in their partner’s
presence • Recent changes in deeds or title to property

• Fear of outside intervention • Rent arrears and eviction notices

• Damage to home or property • Unnecessary property repairs

• Isolation – not seeing friends and family

Modern slavery
• Limited access to money
• Signs of physical or emotional abuse

Online grooming, bullying and abuse • A

If someone is being or has been groomed or abused
online, they might:
 ppearing to be malnourished, unkempt or
withdrawn
• Isolation from the community, seeming under the
control or influence of others

28
• L
 iving in dirty, cramped or overcrowded • Inappropriate or inadequate clothing
accommodation and or living and working at the
same address • Inadequate diet

• Working very long hours and has no money • U

 nexplained weight loss, or other signs of
malnutrition
• L
 ack of personal effects or identification
documents • Untreated injuries or medical problems

• Always wearing the same clothes • Need for dental care not being met

• A
 voidance of eye contact, appearing frightened or • Failure to be given personal hygiene
hesitant to talk to strangers • Poor personal hygiene
• Fear of law enforcers Examples of self-neglect include:

• A
 refusal or inability to cater for basic needs,
Organisational or institutional abuse including personal hygiene and appropriate
• Failure to respond to abuse appropriately clothing

• Failure to respond to complaints appropriately • Neglecting to seek assistance for medical issues

• Insufficient staff or high turnover resulting in poor • N

 ot attending to living conditions – letting rubbish
quality care accumulate in the garden, or dirt to accumulate in
the house
• Persistently failing to their needs
• Hoarding items or animals
• Authoritarian management or rigid regimes

• L
 ack of choices in their home or care setting, for
example, having to go to bed at a certain time

• Not offering choice or promoting independence

• Misuse of medication

• D
 iscouraging visits or the involvement of relatives
or friends

• Inappropriate use of restraints

• Lack of respect for dignity and privacy

• N
 ot providing adequate food and drink, or
assistance with eating

• F
 ailure to provide care with dentures, spectacles or
hearing aids

• N
 ot taking account of individuals’ cultural, religious
or ethnic needs

• Interference with personal correspondence or

communication

Neglect and acts of omission

• Poor physical condition

• Dirty kit

• Clothing in poor condition

29
Safeguarding Policy Season 2019/20 - Appendices

Appendix 2: Safeguarding Referral Form

1. Person(s) whose safety and/or welfare there are concerns about

Please provide known details of the alleged victim(s)/person(s) whose safety and/or welfare there are concerns about

Forename and surname

Date of birth/estimated age:

Relationship to the Premier

League/PLCF:

In the case of a child, please provide their parent’s/legal guardian’s contact details below

Email address:

Contact number

Address:

Please use a continuation sheet for details of additional persons

2. Details of the person(s) whose actions or behaviour there are concerns about

Please provide known details of the alleged perpetrator(s) of abuse/person(s) whose actions or behaviour there are
concerns about

Forename and surname

Date of birth/estimated age:

Relationship to the Premier

League/PLCF:

Other known roles with

children and/or adults at risk:

FAN number:

In the case of a child, please provide their parent’s/legal guardian’s contact details below

Forename and
surname

Contact
number:

Address:

Please use a continuation sheet for details of additional persons

30
3. Details of any witnesses

Please provide known details of any witnesses to the incident

Forename and surname

Date of birth/estimated age:

Relationship to the Premier

League/PLCF:

In the case of a child, please provide their parent’s/legal guardian’s contact details below

Email address:

Contact number

Address:

Please use a continuation sheet for details of additional witnesses

4. Details of the disclosure, incident or concern

Please provide the time, date and location of the disclosure, incident or concern using a continuation sheet if necessary

Date:

Time:

Location:

Please provide:

• A factual account rather than assumption of what you have witnessed or been told
• Clear, concise and relevant information

31
Safeguarding Policy Season 2019/20 - Appendices

32
33
Safeguarding Policy Season 2019/20 - Appendices

5. Details of action taken to date

Please provide:

• Details of all action taken to date including the rationale for taking these actions
• The date, time and contact details of any person and/or organisation to whom this information has been referred

34
6. Details of the person completing this form

Forename and
surname

Relationship
to the Premier
League/PLCF:

Email address:

Contact number:

Address:

Date:

If you are making this referral on behalf of someone else who has reported information to you, please provide their details

Forename and
surname

Relationship
to the Premier
League/PLCF:

Email address:

Contact number:

Address:

Premier League Safeguarding Team

Jess Addicott
Premier League Head of Safeguarding
T: 020 7864 9173
E: safeguarding@premierleague.com

External Safeguarding Contacts

The Football Association Safeguarding Team

T: 0800 169 1863 ask to speak to a member of the Safeguarding Team
(during office hours Mon-Fri excluding bank holidays)
E: safeguarding@thefa.com

POLICE 101 (or 999 in an emergency)

24-hour safeguarding children advice helpline 0808 800 5000

Safeguarding adults advice helpline 0115 951 5400

35
Safeguarding Policy Season 2019/20 - Appendices

Appendix 3: Responding to safeguarding concerns

Flowchart 1 – Children and Young People

The flowcharts in Appendix 3 aim to support Staff and Partners when dealing with a
disclosure, safeguarding incident or allegation

Safeguarding concern about a Child or Young Person

No Is the Child or Young Person in need of Yes

urgent medical treatment?

Is the Event Safeguarding Officer or a member 1. Contact emergency services by calling 999
of the PL Safeguarding Team available? 2. Contact local Children’s Social Care/MASH

Yes No

1. Report the information to the

Event Safeguarding Officer or PL
Safeguarding Team
2. Record the information on a PL Is the matter serious enough to potentially be considered a criminal offence?
Safeguarding Referral Form and
submit to the Event Safeguarding
Officer or PL Safeguarding Team
No Yes / Not sure

Does the allegation or incident involve the Child’s/ Does the allegation or incident involve the Child’s/
Young Person’s parents/legal guardians? Young Person’s parents/legal guardians?

No Yes No Yes

Inform the parents/legal guardians Inform the parents/legal guardians

1. Report the information to the Event Safeguarding
Officer or PL Safeguarding Team
2. Record the information on a PL safeguarding referral
form and submit to the Event Safeguarding Officer or
PL Safeguarding Team
1. Contact the Police to report the information
2. Contact local children’s social care/MASH (if not yet
reported to them)
3. Report the information to the Event Safeguarding
Officer or PL Safeguarding Team
4. Record the information on a PL Safeguarding Referral
Form and submit to the Event Safeguarding Officer
or PL Safeguarding Team

36
Appendix 3: Responding to safeguarding concerns

Flowchart 2 – Adults at Risk

Safeguarding concern about an Adult at Risk

No Is the Adult at Risk in need of urgent Yes

medical treatment?

Is the Event Safeguarding Officer or a member of the 1. Contact emergency services by calling 999
PL Safeguarding Team available? 2. Contact local Adult Social Care

Yes No

1. Report the information to the

Event Safeguarding Officer or PL
Safeguarding Team
2. Record the information on a PL Is the matter serious enough to potentially be considered a criminal offence?
Safeguarding Referral Form and
submit to the Event Safeguarding
Officer or PL Safeguarding Team
No Yes / Not sure

Does the allegation or incident involve the Adult at Does the allegation or incident involve the Adult at
Risk’s parents/carers? Risk’s parents/carers?

No Yes No Yes

Inform the parents/carers Inform the parents/carers

1. Report the information to the Event Safeguarding
Officer or PL Safeguarding Team
2. Record the information on a PL safeguarding referral
form and submit to the Event Safeguarding Officer or
PL Safeguarding Team
1. Contact the Police to report the information
2. Contact local Adult Social Care (if not yet reported
to them)
3. Report the information to the Event Safeguarding
Officer or PL Safeguarding Team
4. Record the information on a PL Safeguarding Referral
Form and submit to the Event Safeguarding Officer
or PL Safeguarding Team

37
Safeguarding Policy Season 2019/20 - Appendices
Appendix 4: Flowcharts – Stakeholder roles and procedures
Flowchart 1 – Low level poor practice concern
Poor practice concern referred to the organisation’s Safeguarding Team
to assess the information and determine the appropriate action.
No
Threshold has not been met and there
are no records of previous concerns
related to this individual.
Dealt with in line with the employer’s
internal policies and procedures.
Possible actions and outcomes (not exhaustive lists)
The employer of the individual
whose conduct there are concerns
about
• Internal investigation.
• Suspension.
• Unfounded/no further action
required.
• Formal disciplinary procedures.
• Disciplinary sanction.
• Training, mentoring, supervision
and/or support.
• Dismissal.
More significant concerns could
emerge during internal processes
that require DBS, statutory and/or
Football Authority referral.
More significant concerns
could emerge during football-
led investigations that
require external referral (see
flowchart on page 39).
38
Football Authority poor practice Yes
referral threshold met?
Referral made to Football Authorities within 24 hours or as soon thereafter as
The Football Authorities will agree the course of action with the
referring organisation.
The employer of the individual whose conduct there are concerns about
• Employer-led internal investigation and outcome shared with the Football
Authorities.
• Joint Football Authority and employer investigation.
• Suspension.
• Formal disciplinary procedures.
• Disciplinary sanction.
• Training, mentoring, supervision and/or support.
Premier League/PLCF acting in a regulatory capacity
• Providing support and guidance.
• Having oversight and working with Clubs to ensure that internal procedures
and football regulations are followed.
• Club/CCO-led internal investigation and the outcome shared with the football
authorities.
• Joint Football Authority and Club/CCO investigation.
• Joint Premier League/PLCF and FA investigation.
• Independent case review (possibly in conjunction with The FA).
• Sanctions against Clubs where Premier League Rules have been breached.
• Suspension or termination of CCO grant payments by the PLCF.
• Work with the Club/CCO to ensure that learning outcomes are implemented to
mitigate risk of recurrence.
• Share anonymised learning from cases to strengthen safeguarding provision.
The FA
• Investigation.
• Risk assessment to determine whether the individual poses or may pose a risk
of harm.
• Training, mentoring, or supervision order.
• Interim or permanent suspension.
Flowchart 2 – Serious poor practice, abuse or criminal offence

Information referred to the organisation’s Safeguarding Team to assess the information and determine the appropriate action.
Note: Any individual can contact emergency services and/or make a referral directly to statutory
agencies if they are concerned about a Child’s or Adult at Risk’s immediate safety. The organisation’s
Safeguarding Team should be informed as soon as practicable after such referral is made.

Referral to the appropriate statutory agencies where thresholds are met.

Referral made to Football Authorities within 24 hours or as soon thereafter as practicable by completing

Possible actions and outcomes (not exhaustive lists)

Statutory authorities The employer of the individual whose conduct there

• Multi-agency strategy meeting. are concerns about

• Criminal investigation/proceedings. • Participate in multi-agency strategy meeting.

• Local Authority investigation. • Implement agreed multi-agency strategy meeting

• A joint Police and Local Authority investigation.
• Care or protection orders issued.
• Statutory authorities determine that their thresholds
evidence. The concern is referred back to manage in
line with football policies, procedures and regulations
(see process in flowchart on page 3820).
Football Authority and/or internal employer procedures
may be delayed pending the outcome of statutory
authority processes and criminal proceedings.
actions.
• Statutory authorities determine that their thresholds
evidence. The concern is referred back to football to
manage.
• Employer-led investigation.
• Joint Football Authority and employer investigation.
• Suspension.
• Formal disciplinary procedures.
• Disciplinary sanction.
• Training, mentoring, supervision and/or support.
• Dismissal.
•
concerns and cases (in consultation with statutory
authorities where appropriate to ensure that there is
no conflict of treatments/support provisions).

The FA Premier League/PLCF acting in a regulatory capacity

• Participation in multi-agency strategy meeting.
• Investigation.
• Risk assessment to determine whether the individual
does or may pose a risk of harm.
• Training, mentoring, or supervision order.
• Providing support and guidance.
• Having oversight and working with Clubs to ensure that
internal procedures and football regulations are followed.
• Club/CCO-led internal investigation and the outcome
shared with the football authorities.

• Interim or permanent suspension. • Joint Football Authority and Club/CCO investigation.

• Joint Premier League/PLCF and FA investigation.
• Independent case review (possibly in conjunction with
The FA).
• Sanctions against Clubs where Premier League Rules
have been breached.
• Suspension or termination of CCO grant payments by the
PLCF.
• Participation in multi-agency strategy meetings.
• Work with Clubs to implement agreed multi-agency
strategy meeting actions.
• Work with the Club/CCO to ensure that learning
outcomes are implemented to mitigate risk of recurrence.
• Share anonymised learning from cases to strengthen
safeguarding provision.

39
Premier League
30 Gloucester Place T +44(0)20 7864 9000
London W1U 8PL F +44(0) 20 7864 9001
premierleague.com E safeguarding@premierleague.com